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SWENT v. COMMISSIONER

Docket No. 4381.

5 T.C. 33 (1945)

J. W. SWENT AND URSULA L. SWENT, HUSBAND AND WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 14, 1945.

Attorney(s) appearing for the Case

Nathan Moran, Esq., for the petitioners.

B. H. Neblett, Esq., for the respondent.

The respondent determined a deficiency of $147.48 in the income tax of each petitioner for the year 1940. Each petitioner also asserts an overpayment of $2,544.94 for that year.

The sole issue is whether or not the petitioner, James W. Swent, is entitled to exclude from his gross income amounts received from sources without the United States, as provided in section 116 (a) of the Revenue Act of 1938.

FINDINGS OF FACT...

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